FEDERAL

After years of drastic cuts to reimbursement, CMS takes a less
aggressive approach to Medicare payment reform… Big data, information
transparency, and stakeholder involvement are key asks of the provider
community in this year’s proposed rule.

Regarding
its impact on the laboratory and pathology community, this year’s
Proposed Rule is rather unique for the following reasons:

1.)Overall Economic Impact on
Pathologists and Laboratories is POSITIVE: Over the past
few years, the pathology and laboratory community have endured or, at
the very least, been threatened by dramatic cuts to reimbursement via
the payment rates and policies proposed and/or finalized in the annual
PFS/CLFS. However, this year, the overall impact on pathologists is
actually rather favorable, estimated at one percent ($1.07 billion) of
total Medicare Part B allowed charges. Similarly, the overall impact on
independent laboratories is estimated at three percent ($703 million)
of total allowed charges. Conversely, last year’s estimated impacts
were -5 percent and -26 percent, respectively.

2.)Omitted Policy May be of
Greater Significance than Policies Actually Included: In
a major and unexpected victory for the laboratory and pathology
community, CMS did not revisit the “OPPS Cap Proposal,” as it
previously stated that it had intended to do in last year’s PFS Final
Rule. Under the proposal, CMS had proposed to cap PFS payment rates at
hospital payment rates when the former exceeded the latter for a given
service. ASCP adamantly opposed this proposal and, in response, led a very
successful e-advocacy campaign,
resulting in nearly 10,000 messages to CMS and Congress in opposition
to it. ASCP is extremely pleased that CMS has finally realized that the
“comparison of OPPS (or ASC) payment amounts to PFS payment amounts for
particular procedures is not the most appropriate or effective approach
to ensuring that PFS payment rates are based on accurate cost
assumptions.”Nonetheless, ASCP notes that
although CMS recognizes commenters’ concerns with using OPPS/ASC
payment amounts as benchmarks for PFS payment rates, given that they
reflect average rates/ relative weights rather than direct cost inputs,
the Agency is still interested in using outpatient hospital cost data
as a benchmark for pricing non-facility based Medicare services and
seeks comment accordingly.

3.)Significant Legislative
Overlap Considerations and Implications: The annual
publication of the PFS occurs through the federal government’s
regulatory process. It is typically completely separate from the
legislative process, though often times CMS’s regulatory authority is
restricted by what is “set in statute” via legislation. Hence,
Congress’s April 1 passage of H.R.
4302, The Patient Access to Medicare Act, significantly
impacts the content of this year’s PFS. First, there is little mention
of the -20.9 percent PFS update threatening physicians’ Medicare
reimbursement as a result of the Sustainable Growth Rate (SGR) payment
formula because PAMA averts this cut through March 2015. Second, PAMA
repealed CMS’s authority to revalue the CLFS payment rates based on
technological change, as previously finalized in last year’s PFS Final
Rule, and replaced the revaluation process with a market-based
approach that relies on the collection of test-specific price
and volume information from private sector payors. Hence, CMS does not
touch upon this now statutory-based proposal in this year’s PFS.
Additionally, PAMA established nine additional categories for review
when identifying potentially misvalued codes, which may have
significant additional impact on the type and number of codes up for
review when added to the existing seven categories.

4.)Unprecedented Transparency
and Stakeholder Involvement in Payment Rate-Setting:
This year, CMS is placing unprecedented emphasis on large-scale,
cost-based data collection and payment rate-setting transparency.
Accordingly, in lieu of merely dictating changes to payment rates that
have already been decided upon behind closed doors, the Agency is
exerting its newly enhanced information collection authority via PAMA
and reforming its existing timeline for misvalued code nominations and
proposals to improve information transparency and increase opportunity
for stakeholder input. As such, beginning with the CY 2016 PFS Proposed
Rule, CMS will include all CMS-proposed values and all values proposed
by the American Medical Association/Specialty Society Relative Value
Scale Update Committee (RUC) that have been received by Jan. 15, 2015.
Values proposed by the RUC, but not received by CMS by this date, will
be delayed for consideration for one year and included in the following
year’s PFS Proposed Rule in order to allow sufficient time for public
comment.

Key Provisions Impact the Pathology and Laboratory Community
in the CY 2015 PFS Proposed Rule:

In this proposal, CMS responds to PAMA’s specification that
local coverage decisions (LCDs) are to be the mandated vehicle for
local coverage policies for clinical diagnostic laboratory tests.
Recognizing the need for immediate reform, CMS addresses the challenges
experienced throughout the recent molecular pathology valuation process
and looks to the National Coverage Determination (NCD) process as a
more efficient model for an expedited LCD process. Accordingly, while
CMS believes some key aspects of the LCD process should be maintained,
such as allowing public comment to draft LCDs, and MAC responses to
public comments, the Agency believes there is significant opportunity
for streamlining it. The goal of this proposal is to balance the need
to allow enough time for notification of stakeholders and public
dialogue with the need to finalize a large number of LCDs in a timely
manner in order to expedite beneficiary access to covered clinical
diagnostic laboratory tests. Reference page 228 of the CY
2015 PFS Proposed Rule:Table 18 Comparison of
Current LCD Process versus Proposed LCD Process for Clinical Diagnostic
Laboratory Tests below.

Potentially Misvalued Codes:

Flowcytometry/tc
add-on: CMS has identified 65 codes as a prioritized
subset of potentially misvalued codes of the newly established
statutory category finalized with the passage of PAMA, entitled “codes
that account for the majority of spending under the PFS.” The majority
of spending is defined as greater than or equal to $10 million in
allowed charges. Accordingly, only one pathology code was identified
via this methodology: CPT Code- HCPCS 88185, Flowcytometry/tc add-on.
Nonetheless, CMS actually proposes to increase reimbursement for this
code by 5.3 percent (1.5à1.58 RVUs) this year, as proposed in the CY
2015 PFS Proposed Rule’s Addendum B – Relative Value Units and Related
Information.

Prostate
Biopsy Codes – HCPCS codes G0416, G0417, G0418, and G0419:
Based on CMS’s argument that the number of specimens associated with
prostate biopsies is relatively homogenous, the Agency is proposing to
eliminate all of the g-codes except for G0416, which assumes the lowest
number of specimens evaluated for prostate biopsies (10-20
specimens/biopsy). Based on review of medical literature and claims
data, CMS maintains that the appropriate number of specimens reviewed
per biopsy is typically between 10 and 12. Therefore, the Agency is
proposing G0416 as a potentially misvalued code and seeks comment on
the appropriate work RVUs, work time, and direct practice expense (PE)
inputs. Currently, G0416 is paid at $651.26.

Physician Quality Reporting System (PQRS)

This year, CMS’s proposals focus primarily on the CY 2017
payment adjustment, based on the CY 2015 reporting period, as well as
the Agency’s efforts to align quality reporting programs, specifically
through the Qualified Clinical Data Registry (QCDR) reporting
mechanism. It should be noted that since CY 2014 was the last reporting
period in which EPs could earn an incentive payment, quality reporting
requirements for the CY 2015 reporting period are focused solely on
avoiding application of the -2 percent CY 2017 payment adjustment.
Lastly, in this proposed rule, CMS seeks comments broadly regarding
whether or not the Agency should allow more frequent submission of
data, such as quarterly or year-round submissions, rather than having
only one opportunity to submit quality measures data as is the case
under the current process.

CMS introduces an additional reporting requirement for EPs
reporting via claims or registry that have at least one face-to-face
encounter; they must report on at least two cross-cutting measures

CMS pushes the group practice registration deadline from
Sept. 30 of the reporting period year to June 30 of the reporting
period year

CMS specifies that all group practices must report
measures on 248 patients (rather than 411 patients for groups of 100+
EPs or 218 patients for groups of 25-99 EPs)

Though CMS will no longer fund reporting, CMS proposes to
require all groups of 100+ EPs to report the Consumer Assessment of
Healthcare Providers and Systems (CAHPS) for PQRS survey measures.
Reporting these measures remains optional for groups of 2-99 EPs in CY
2015

CMS proposes to increase the number of non-PQRS measures
allowed for reporting via a QCDR from 20 to 30

CMS proposes that QCDRs make available to public its EPs’
quality measures data in CY 2015

CMS proposes to allow an entity that uses an external
organization for purposes of one or more QCDR functions to still
qualify as a QCDR as long as it has a signed agreement with the
external entity as of Jan. 1 of the year prior for which it wishes to
become a QCDR

CMS proposes to extend the deadline for QCDRs to submit
quality measures data calculations and results from the last Friday two
months after the end of the reporting period to March 31 following the
end of the applicable reporting period

Value-Based Payment Modifier Program

CMS proposes to increase the amount of payment at risk under
the Value-based Payment Modifier (VBM) program from +/-2 percent in CY
2016 (based on the CY 2014 reporting period) to +/-4 percent in CY 2017
(based on the CY 2015 reporting period). As required by statute,
beginning in CY 2017, based on the CY 2015 reporting period, CMS will
begin applying the value modifier to physicians in groups of physicians
with two or more EPs and to physicians who are solo practitioners. Solo
practitioners are defined as a single Tax Identification Number (TIN)
with one EP who is identified by an individual National Provider
Identifier (NPI) billing under the TIN. Similarly, though not required
by statute, CMS will also begin applying the value modifier to
non-physician practitioner EPs in groups of two or more EPs as well as
solo non-physician practitioners. Lastly, unlike previous years, CMS
will begin applying the value modifier to physicians and non-physician
EPs participating in the Shared Savings Program, the Pioneer ACO Model,
the CPC Initiative, or other similar Innovation Center models/CMS
initiatives starting in CY 2017. Reference Table 55:
Eligible Professional/ Physician Group Size Distribution (2012 claims)
on page 447 of the CY 2015 Proposed Rule.

Also in the CY 2015 PFS Proposed Rule, CMS proposes the
following:

Quality-tiering is mandatory for all EPs, however groups
of 2-9 EPs and individual EPs will be exempt from downward payment
adjustments, regardless of performance

Because the two programs have two very methodologically
dissimilar approaches to calculating cost benchmarks, CMS proposes that
classify the cost composite for the value modifier as “average cost”
for groups of EPs participating in ACOs during the payment adjustment
year

Because CMS is unable to calculate a benchmark for
QCDR-developed measures, performance on these measures will not be
included in the quality composite score

CMS proposes to change the reliability policy with respect
to the “all-cause hospital readmissions” measure by increasing the
minimum number of measures required to report on the measure from 20 to
200 for CY 2015

CMS proposes to establish a deadline of Jan. 31, 2015 for
a group to request correction of a perceived error made by CMS
regarding its CY 2015 value modifier payment adjustment

Lastly, probably the most significant item within the VBM
program section of the CY 2015 Proposed Rule is an item that wasn’t
actually formally proposed.CMS is considering
including or allowing groups that include hospital-based physicians or
solo practitioners who are hospital-based to elect the inclusion of
Hospital Value-Based Purchasing (VBP) Program performance in their VM
calculation in future years of the program. This consideration is in
response to commenters past suggestions, noting that there are limited
measures that apply to certain specialties and that those specialties
may exercise wide influence over the quality of care provided in a
hospital.

For an ASCP-developed summary, containing a more complete
description of the provisions within the CY 2015 PFS Proposed Rule with
greatest impact on the pathology and laboratory community, click here.

Laboratory Community Urged to Drive Transition into the Next
Generation of Health Information Exchange

Five
Years Later, Federal Agencies Realize the Critical Role of Laboratory
Professionals in Ensuring the Safe, Robust, and Fully Interoperable
Electronic
Transfer of Patient Health Information

✓ The
Cumulative Meaningful Use (MU) Program payments
paid to Eligible Hospitals (EHs) and Eligible Professionals (EPs) as of
May
2014[i]...
$24 Billion

✓ The
Electronic Health Record (EHR) vendor market as of
2012[ii]...
$20 Billion

✓ That
moment when the Federal Government finally
realizes the essential role of the laboratory community in ensuring the
MU
program's successful transition from a mere quality reporting to a
quality
improvement program...PRICELESS

Despite the
laboratory community’s substantial financial contributions aiding in
the
facilitation and acceleration of the meaningful use of EHRs, as indicated above,
pathologists have remained
essentially ineligible to participate in the MU program since its onset
in 2011.
Accordingly, though CMS granted pathologists a formal five-year
exemption from
the negative payment adjustments set to begin in 2015, the laboratory
community
is still incurring both opportunity and real cost resulting from their
inability to participate in the MU program. To date, pathologists have
incurred
a cumulative $530 million in opportunity cost and millions more in real
cost,
given the substantial investments that laboratories have made in EHR
systems,
interfaces, and general interoperability on behalf of their referring
clinician
offices.

Yet as the
Center for Medicare and Medicaid Services (CMS) strives to expand the
quantity
and diversity of patient health information (PHI) within a patient’s
EHR, the
Agency is increasingly looking to push and pull additional PHI types to
and
from a large variety of non-EHR HIT systems across a broad range of
clinical
settings. Similarly, the Office of the National Coordinator (ONC) is
increasingly looking to specialty providers to help shape the policy,
certification, and standards development underlying the transmission,
incorporation, and utilization of specialty-specific data within an EHR.

Accordingly,
two very recently published reports from the Centers for Disease
Control and
Prevention (CDC) and the Agency for Healthcare Research and Quality
(AHRQ)
highlight the important contributions that laboratory professionals can
make to
facilitate and accelerate the seamless interoperable exchange of
laboratory
data both now and in the future.

Further,
based on concerns expressed by the Clinical Laboratory Improvement
Advisory
Committee (CLIAC) that laboratory-related interoperability issues and
laboratory data display discrepancies in EHRs may pose a serious threat
to
patient safety, CDC convened a team of experts to further research the
issue.
As such, the publication of this white paper is intended to highlight
the
potential for serious risk to patient safety in the implementation of
EHR
systems and offer several high-level recommendations to mitigate risk.
The
three key recommendations, presented jointly by CDC’s Communication in
Informatics Workgroup (CIIWG) and CLIAC are presented below:

2.)Data
Integrity and Usability: Ensure that laboratory data are
accurately presented
in the EHR and available at the point-of-care to reduce laboratory
data-related
errors (i.e. development of consensus-based information exchange
standards in
compliance with CLIA regulatory requirements)

In April
2014, the MITRE Corporation, a
not-for-profit national technology
resource that provides systems engineering, research and development,
and
information technology support to the government, prepared a report for
AHRQ,
entitled “A
Robust
Health Data Infrastructure.” The report hypothesized the
future landscape
of HIT, identifying the possible benefits of advanced health
information
exchange (HIE), proposing innovative software architecture, and
predicting the
EHR data types of the future. In particular, this report suggests that
improved
HIE and a more comprehensive picture of patient health via access to a
more
robust dataset has the potential to: (1)
Substantially improve care
coordination; (2) Enhance patient access; (3)
Reduce errors within
and across patient records; (4) Reduce redundant
testing and diagnostic
procedures; (5) Enable longitudinal tracking of
individual and
population health; (6) Reinforce standards of care
to mitigate clinical
errors; (7) Inform biomedical research; (8)
Enable automated,
electronic detection of fraud; and (9) Improve
tracking of healthcare
costs and benefits to instill a better understanding of the healthcare
economics underlying service delivery.

Moreover,
in order to fully realize the potential benefits listed
above, the report offers a proposal for the ideal software
architecture, suggesting
the following core principles:

Be
agnostic as to the type, scale, platform, and storage location of the
data

Use
public Application Program Interfaces (APIs) and open standards,
interfaces,
and protocols

Encrypt
data at rest and in transit

Separate
key management from data management

Include
with the data the corresponding metadata, context, and provenance
information

Represent
the data as atomic data with associated metadata

Follow
the “robustness principle”: be liberal in what you accept and
conservative in
what you send

Lastly, the
report
hypothesizes that the “EHR data types of the future” will include
genomic data
(“omic” data), expression data, patient-reported data from embedded and
wireless sensors, and population health data gleaned from open-sources.
In
particular, the report identifies the following “omic” data and their
perceived
future benefits for enhancing the provider’s understanding of patient
condition:

Genome
Sequence:to
capture all of
the genetic variation of an individual in comparison to the reference
human
genome sequence

Transcriptome: Similar to a genome sequence but
further captures
variables of cell state, thereby generating larger and more
personalized
datasets

Epigenome:
Allows for
spatial
resolution of particular modifications in the genome

Proteome:
Describes the
types and amounts of proteins
expressed from the genome

Microbiome:
Offers a
complete description of the human
body’s microbial cells, which allows for the potential detection and
correction
of aberrant states linked to pathogenic conditions

Immunome:
A description of
the
state of the immune system of an individual, focusing on the diversity
of
immune responses based on past exposures; high-throughput methods now
allow
testing for reactivity to thousands of antigens at once

Sylvia Mathews Burwell was confirmed as the new Secretary of Health and
Human Services (HHS) on May 22. Transitioning from her role
as the Director of the Office of Management and Budget (OMB), she
enters the HHS with experience in both the private and public sector.

An overwhelming majority of 78-17 confirmed her nomination and Senate
Republicans are hopeful that Burwell will be open to hearing their
concerns regarding the highly polarizing Affordable Care Act. Following
the resignation of her predecessor, Kathleen Sebelius, she faces
tremendous pressure to improve implementation of the ACA at the state
level and online. With her ability to inspire bipartisan support and
impressive credentials, Burwell is well positioned to accomplish these
challenging tasks.

PRACTICE

CMS to Cover HCV Screening

The
Centers for Medicare & Medicaid Services (CMS) announced
on June 2 that
Medicare and Medicaid will cover screening for Hepatitis
C virus (HCV). CMS's recent determination to cover HCV
screening is
consistent with the recommendations by the U. S. Preventive Services
Task
Force. CMS indicated that it will cover screening for HCV with the
appropriate
U. S. Food and Drug Administration (FDA) approved/cleared laboratory
tests,
used consistent with FDA approved labeling and in compliance with the
Clinical
Laboratory Improvement Act (CLIA) regulations, when ordered by the
beneficiary's primary care physician or practitioner within the context
of a
primary care setting and performed by an eligible Medicare provider for
these
services, for beneficiaries who meet either of the following
conditions:

A screening test is
covered for adults at high risk for Hepatitis C Virus infection. "High
risk" is
defined as persons with a current or past history of illicit injection
drug use
and persons who have a history of receiving a blood transfusion prior
to 1992.
Repeat screening for high-risk persons is covered annually only for
persons who
have had continued illicit injection drug use since the prior negative
screening test.

A single screening
test is
covered for adults who do not meet the high risk as defined above, but
who were
born from 1945 through 1965.

CMS
stated in a national coverage decision that "the evidence is adequate
to
conclude that screening for Hepatitis C Virus (HCV), consistent with
the grade B
recommendations by the U. S.
Preventive Services Task Force
(USPSTF), is reasonable and necessary for the prevention or early
detection of
an illness or disability and is appropriate for individuals entitled to
benefits under [Medicare] Part A or enrolled under Part B."

Previously
in 2012, the U. S. Centers for Disease Control and Prevention (CDC)
also
recommended that all Baby Boomers, those born between 1945 and 1965,
should
have a one-time blood test to screen for HCV, which often goes
undetected and
can take years to cause serious illness. Untreated, HCV can eventually
cause
liver disease and liver cancer.

New Genetic Test Diminishes Risk for Transfusion Reaction

Medical diagnostic technology is continuously improving the
precision of test results and providing targeted diagnosis and
treatment. While the healthcare industry is moving closer to the
personalized medicine standard of care, advancements in test
specificity require adequate justification for their utilization. In
particular, the justification for a closer matched unit of blood in the
blood banking industry using genotype testing was at the heart of the
discussion at recent Capitol Hill briefing entitled “Blood Safety: The
Importance of Diagnostics and Devices.”

Under current serologic testing, one to five percent of patients mount
an immune response to infused blood. However, certain subgroups, such
as those with Sickle Cell Disease or individuals with bone marrow
failure, may develop certain conditions which result in reliance upon
chronic infusions. Of those chronically-infused patients, between 12
and 39 percent mount an antibody response to traditionally
cross-matched blood.

To provide adequately matched blood to these populations, Immucor
presented a genetic test which identifies 35 clinically significant
antigens at the AMA Pathology Coding Caucus. This test was granted PMA
approval and the CPT tier 2 code 81403 will be active July 1, 2014.

WORKFORCE

HRSA Announces Formation of the Bureau of Health Workforce

The Health Resources and Services Administration (HRSA)
announced the formation of a new bureau, the Bureau of Health Workforce
(BHW). This bureau will now oversee the programs administered by the
Bureau of Health Professions and the Bureau of Clinician Recruitment
and Service. Led by Associate Administrator Rebecca Spitzgo,
BHW will help HRSA achieve its mission of improving health and
achieving health equity through access to quality services, a skilled
health workforce and innovative programs.

According to BHW, the programs and activities will be
implemented to:

Train the next generation of diverse healthcare providers
to serve underserved populations through its grants to health
professions schools and training programs.

Examine a broad range of issues that impact the supply,
demand, distribution, and education of the Nation’s health workforce
and provide policymakers with the information necessary to make
informed decisions regarding the health professions workforce and
provision of care.

Support graduate medical education.

Recruit and retain providers and students to underserved
areas through both the National Health Service Corps and NURSE Corps
Scholarship and Loan Repayment Programs.

Protect the public from healthcare practitioners,
providers, and suppliers with a history of malpractice, adverse
actions, fraud and abuse through the National Practitioner Data Bank.

This restructuring
will allow for increased connectivity between programs and with
particular focus on the distribution of the health
workforce. To prepare for the influx of newly-covered
individuals under the ACA, the bureau will provide informational
materials to be distributed to patients. Topics include when and where
to seek care and the importance of prevention and a steady healthcare
provider. Materials are available at the coverage to care website and
can also be found at marketplace.cms.gov. For more
information, visit the BHW website at: http://bhw.hrsa.gov/

GLOBAL HEALTH

New Global AIDS Coordinator Outlines Next Phase for PEPFAR

The key to delivering an AIDS-Free Generation, according to
Ambassador Deborah L. Birx, MD, the New Global AIDS Coordinator, is
“delivering the right thing in the right place at the right time.”
Ambassador Birx shared her vision for the next phase of the U. S.
President’s Emergency Plan for AIDS Relief (PEPFAR) to support efforts
for an AIDS-free generation during a recent town
hall event hosted by the Kaiser Family Foundation.

By “the right things,” Ambassador Birx referred to the core
PEPFAR activities, those critical to saving lives and preventing new
infections. These high-impact interventions include prevention
activities, support services for orphans and vulnerable children as
well as neglected and/or hard to reach populations, and strengthening
health systems to specifically support these interventions. Equally
important is ensuring these interventions are geographically focused
and reaching the most vulnerable populations in an effective way. And
finally, the timing of these interventions will be critical to PEPFAR’s
success by preventing new infections among the most vulnerable
populations and in the highest prevalence areas. Ambassador Birx also
promised greater accountability through cost-effective programming
designed to maximize impact of every dollar invested and transparency
through validation and sharing of all levels of program data.

Through PEPFAR, ASCP Global Outreach has been working around
the world since 2005 to improve laboratory quality and patient health
outcomes. ASCP staff and consultants have facilitated more than 120
trainings, workshops, and mentorships and trained more than 2,200
laboratory professionals and medical laboratory instructors worldwide.
These activities have comprised subject-specific, hands-on trainings as
well as university curriculum improvement, teacher trainings, and
laboratory accreditation and quality improvement projects.

STUDIES

Demystifying the Logic of the ACA: From Eligibility to Coverage to
Care

Fifty-six percent of America’s uninsured may be eligible for
coverage under the Affordable Care Act (ACA), but it is estimated that
half of the uninsured in expansion states and one-third of the
uninsured in non-expansion states will actually enroll, according to a
new report from the Robert Wood Johnson Foundation (RWJF).

With significant differences in eligibility based on a state’s
decision to expand Medicare coverage, 68 percent of the uninsured
became eligible for assistance in expansion states, compared to only 44
percent in non-expansion states. Texas, Mississippi, Louisiana, and
Georgia currently hold the lowest shares of eligibility for assistance
under the Affordable Care Act (ACA). Unfortunately, these regions also
have large share of residents who fall into a coverage gap; this
comprises individuals whose income is below 100 percent of the federal
poverty level but remain ineligible for assistance due to their state’s
opt-out of Medicaid expansion. An outlier in this trend is the
non-expansion state of Wisconsin, which will have 75 percent of its
uninsured residents eligible for assistance. However, this is the
result of a recent change in Wisconsin’s Medicaid waiver which expanded
Medicaid eligibility to adult non-parents. In contrast, Massachusetts
is an expansion state which has already implemented its own health
reform law to expand coverage and will thus largely be unaffected by
the ACA. For more state-specific statistics, please refer to Eligibility
Assistance and Projected Changes in Coverage Under the ACA: Variation
Across States by the RWJF.

Eligibility and coverage predictions for the uninsured are
important indicators for care delivery, but do not directly correlate
with the percentage of individuals who will truly receive appropriate
care under the ACA. Education regarding the utilization of our
healthcare system once enrolled is an essential component in the
implementation of the ACA and will require adaptation from both
patients and providers. To aid in this transition, the Centers for
Medicare and Medicaid Services (CMS) launched its "From Coverage to
Care" initiative on June 16 to answer questions and inform
newly-enrolled individuals of the preventative and primary care
services available in their communities.